Data Protection and Privacy Policy

General Information and Introduction

Manchester Historic Buildings Trust is the name of the charity that was founded to preserve and operate Elizabeth Gaskell’s House, including Elizabeth Gaskell House Trading Company. This policy covers all activities by the Trust and the Trading Company.

Elizabeth Gaskell’s House is a historic house and museum that celebrates the life and work of Elizabeth Gaskell, one of the UK’s most important Victorian writers and part of Manchester’s cultural heritage.

The House has been open to the public since October 2014 and, as well as general admissions, offers an event programme (both online and in-person), changing exhibitions, venue and wedding hires, schools and groups visits, Friends scheme for supporters of the house. Elizabeth Gaskell’s House holds a collection of items dating largely from the 19th century, chosen to match Gaskell family records or to be period-appropriate for a mid-Victorian family home. There are a small number of original objects which belonged to either Elizabeth or her family, most of which are on-loan.

We have a legal duty to protect any information we collect from you and to prevent any unauthorised access to or use of that information. We do not pass your details to any third party unless you give us permission to do so. We use only trusted third party solutions to deliver different aspects of your relationship with us, for example the delivery of e-newsletters. We follow current UK data protection law.

Your relationship with us and your data are extremely important to us and we take all necessary steps to protect your data. We will never sell your personal data.

This Data Protection and Privacy Policy sets out how and why we use the personal data you provide to us, which will differ depending on how you interact with us. The policy covers electronic and physical data including how we access, collect, store, use, share, protect and dispose of your data.

Please read the sections that apply to you.

Who Are We?

Elizabeth Gaskell’s House (Manchester Historic Buildings Trust)

84 Plymouth Grove
Manchester
M13 9LW

https://elizabethgaskellhouse.co.uk
We are a registered charity and our charity number is 1080606

Personal Data

When we talk about “personal data”, we mean information that identifies a living person, or which can be identified as relating to a living person. When we talk about “you” or “your” in this policy, we mean any living person whose personal data we collect.

Retention Periods

We will only ever collect the information we need. When we ask you to provide your personal information, we will let you know why we are asking and how we will use your data, by directing you towards this notice.

We hold your information only as long as necessary for the purpose it was collected. This is outlined in our ‘Record of Processing’ which details how long we keep each type of data for.

If you decide to no longer support Manchester Historic Buildings Trust or Elizabeth Gaskell’s House, or request that we have no further contact with you, we will keep some basic information in order to avoid sending you unwanted communications in the future.

Responsibility for Data Protection

The House Director is the appointed Lead for Data Protection (see “How to Contact Us”).

However ultimate responsibility for the oversight of the organisation’s legal responsibilities for data protection, and that staff are following due process as laid out in this policy, lies with the Board of Trustees. If any staff or volunteers are in breach of the policy, then standard disciplinary procedures will be followed and the Information Commissioner’s Office (ICO) will be informed of any data breaches.

1.    If you visit the House or our events

What We CollectWhyLegal Basis
We may collect your name, postal address, email address and phone numberIf you sign up to Gift Aid we are required to obtain your name and postal addressIt is a legal requirement for this process.
 To send you your tickets, or a link to access an online event*This is required for the contract (sale of the product or service)
 We may need to contact you if there is a change to an activity you have booked forThis is required for the contract (sale of the product or service)
 We would like to keep you up to date with news about the house, our events, opportunities, special offers and ways of supporting Elizabeth Gaskell’s House and the Trust.We will only send you these communications via email if we have your consent to do so
Payment detailsTo buy a ticket for an exhibition or event we require these details to process the sale. We do not receive or retain these details if you pay online or via the Welcome desk. Any information you provide to us over the phone will be securely destroyed.This is required for the contract (sale of the product or service)
CCTV footageFor your safety and security CCTV is in operation in public areas of Elizabeth Gaskell’s House. This footage is stored temporarily, and CCTV signage is prominently displayed.Our and your legitimate interests – keeping you, our buildings, people and collections safe
Booking and Transaction History (including admission, events and donations)For our records so we can monitor customer behaviour, patterns and trends to inform our business planning.Our legitimate interests.   You will only be sent communications via email if we have your consent to do so.    

* We use third party providers to manage and broadcast our online events. Please see page 17 to understand more about how we share your data.

2.    If you become a Friend or are gifted a Friend’s membership

Our Friends of Elizabeth Gaskell’s House are also Members of Manchester Historic Building’s Trust. Friends and Members can be considered to mean the same thing in this policy.

What We CollectWhyLegal Basis
We may collect your name, postal address, email address and phone numberTo contact you regarding your Membership, provide you with your Membership benefits including Friends Newsletter updates and notices about AGM or fulfilling legal duties to the house as a member of Manchester Historic Buildings Trust.This forms part of the Terms and Conditions of your Membership contract with us.
 If you sign up to Gift Aid we are required to obtain your name and postal addressIt is a legal requirement for this process.
 We may need to contact you if there is a fundamental change to the terms of MembershipThis is required for the contract (sale of the product or service)
 We would like to keep you up to date with news about the house, our events, opportunities, special offers and ways of supporting Elizabeth Gaskell’s House and the Trust.We will only send you these communications via email if we have your consent to do so
Bank and payment detailsTo allow us to set up your direct debit, standing order, or process your payment.This is required for the contract (sale of the product or service)
Booking and Transaction History (including admission events and donations)For our records so we can monitor customer behaviour, patterns and trends to inform our business planning.Our legitimate interests.   You will only be sent communications via email if we have your consent to do so    

If you buy a Friend Membership as a gift:

What We CollectWhyLegal Basis
We may collect your name, postal address, email address and phone numberTo contact you in relation to membership you are purchasing as a gift.This forms part of the Terms and Conditions of your Membership contract with us.
 If you sign up to Gift Aid we are required to obtain your name and postal addressIt is a legal requirement for this process.
 We would like to keep you up to date with news about the house, our events, opportunities, special offers and ways of supporting Elizabeth Gaskell’s House and the Trust.We will only send you these communications via email if we have your consent to do so
Bank and payment detailsTo allow us to set up your direct debit, standing order, or process your payment.This is required for the contract (sale of the product or service)
Booking and Transaction History (including admission events and donations)For our records so we can monitor customer behaviour, patterns and trends to inform our business planning.Our legitimate interests.   You will only be sent communications via email if we have your consent to do so    

3.    If you are a customer of our Gift Shop or Online Shop

What We CollectWhyLegal Basis
We may collect your name, postal address, email address and phone numberTo provide you with the products you purchase and their receiptThis forms part of the Terms and Conditions of your Membership contract with us.
 We would like to keep you up to date with news about the house, our events, opportunities, special offers and ways of supporting Elizabeth Gaskell’s House and the Trust.We will only send you these communications via email if we have your consent to do so
Bank and payment detailsWe require these details to process the sale. We do not receive these details if you pay online or by card in our Gift shops. Any information you provide to us over the phone will be securely destroyed.This is required for the contract (sale of the product or service)
Booking and Transaction History (including admission events and donations)For our records so we can monitor customer behaviour, patterns and trends to inform our business planning.Our legitimate interests.   You will only be sent communications via email if we have your consent to do so    

4.    If you subscribe to our newsletter and emails

What We CollectWhyLegal Basis
We may collect your email address and communication preferencesWe would like to keep you up to date with news about the house, our events, opportunities, special offers and ways of supporting Elizabeth Gaskell’s House and the Trust.We will only send you these communications via email if we have your consent to do so

If you consent to receive information by email, your email address and communication preferences are held by MailChimp, which is the email marketing system we use to send out e-newsletters, and they are used only for the purpose of sending you these communications.

You can choose to opt out of these marketing communications at any time by contacting us at enquiries@elizabethgaskellhouse.co.uk or by using the unsubscribe link at the bottom of every e-newsletter.

5.    If you make an enquiry about booking a wedding, hiring a space within the house, booking a private group or school tour

What We CollectWhyLegal Basis
Your name, contact address, personal e-mail address, telephone numberTo enable us to respond to your enquiry about a booking or reservation.This is required for the contract (sale of the product or service)  
 To enable us to respond to Freedom of Information requests, complaints and requests made under Data Protection legislationThis is a legal requirement
   

6.    If you book a wedding or hire the space

What We CollectWhyLegal Basis
We collect your name, postal address, email address and phone numberTo enable us to make the booking and ensure we can contact you.This forms part of the Terms and Conditions of your service contract with us.
Payment detailsTo allow us to process your payment.This is required for the contract (sale of the product or service)
 We would like to keep you up to date with news about the house, our events, opportunities, special offers and ways of supporting Elizabeth Gaskell’s House and the Trust.We will only send you these communications via email if we have your consent to do so.
   




7.    If you make a financial donation to Elizabeth Gaskell’s House or Manchester Historic Buildings Trust

What We CollectWhyLegal Basis
We may collect your name, postal address, email address and phone numberIf you sign up to Gift Aid we are required to obtain your name and postal addressIt is a legal requirement for this process.
 We would like to keep you up to date with news about the house, our events, opportunities, special offers and ways of supporting Elizabeth Gaskell’s House and the Trust.We will only send you these communications via email if we have your consent to do so.
Bank detailsTo allow us to process your payment.This is required for the contract (sale of the product or service)

8.    If you enter a prize draw

What We CollectWhyLegal Basis
We may collect your name, postal address, email address and phone numberTo contact you if you winOn the basis of legitimate interests – to contact you if you win.
 We would like to keep you up to date with news about the house, our events, opportunities, special offers and ways of supporting Elizabeth Gaskell’s House and the Trust.We will only send you these communications via email if we have your consent to do so.

We will destroy your personal data after the competition has closed unless you have expressly chosen to opt-in to our email list. See Section 5.

9.    If you visit our website

Cookies

In order to make the Elizabeth Gaskell’s website easier to use and improve our service, we sometimes place small amounts of information on your computer. These are known as cookies and they are used by most major websites. You may refuse the use of cookies on our websites by choosing the appropriate settings on your browser, however some functionality may be lost.

We do not collect any information about your use of cookies. Cookies on our websites are not persistent (i.e. once you close the browser window they are no longer active).

However, occasionally we use retargeting, which does use persistent cookies. This means that if you accept the use of cookies on our websites, you may see adverts for Elizabeth Gaskell’s House content elsewhere on the web. You can opt-out of the collection and use of information for adverts targeting by visiting:

http://www.youronlinechoices.eu/ or www.aboutads.info/choices.

Intellectual Property

You may not copy, reproduce, republish, download, post, broadcast, transmit, make available to the public, or otherwise use the site content in any way except for your own personal, non-commercial use. You also agree not to adapt, alter or create a derivative work from any of the site content except for your own personal, non-commercial use. Any other use of the site content requires the prior written permission of Manchester Historic Buildings Trust.

Manchester Historic Buildings Trust is not responsible for the contents or reliability of any site to which it is linked and does not necessarily endorse the views expressed within them. Linking to or from this site should not be taken as endorsement of any kind. We only link to our sponsoring bodies, exhibition and museum partners and other government departments.

Virus protection
We cannot accept any responsibility for any loss, disruption or damage to your data or your computer system which may occur whilst using material derived from this website.

10. Managing our Collections

Sometimes we hold personal data to manage the collections of Manchester Historic Buildings Trust.

What We CollectWhyLegal Basis
We may collect your name, postal address, email address, phone number and date of birth.To record the details of disposals from and gifts, purchases and loans to our collectionsIt is necessary for us to carry out our Public Task or exercise our official authority as a Museum and it is a legal requirement for this process.  
 To record and manage details of makers/creators of items in our collectionsIt is necessary for us to carry out our Public Task or exercise our official authority as an accredited museum
 To enable us to lend items to other institutions or researchersIt is necessary for us to carry out our Public Task or exercise our official authority as a Museum and it is a legal requirement for this process.
 To ensure that we comply with copyright legislation when providing copies of items in our collectionsThis is a legal requirement for this process
 To undertake object conservation and/or scientific analysis (for outside agencies)This is a legal requirement for this process and forms part of the Terms and Conditions of contract with us.

11. If you contact us with a general enquiry

What We CollectWhyLegal Basis
Your name, contact address, personal e-mail address, telephone numberTo enable us to respond to your general business enquiryOn the basis of Legitimate Interests
 To enable us to respond to Freedom of Information requests, complaints and requests made under Data Protection legislationThis is a legal requirement
 To enable us to respond to enquiries about our collectionsThis is part of our Public Task as a Museum
 To enable us to respond to your enquiry about a booking, purchase or reservation.This is required for the contract (sale of the product or service)

12. If you supply us with goods or services

What We CollectWhyLegal Basis
Your name, company name, contact address, e-mail address, telephone numberTo enable us to make payments, send remittances, answer queries etc. and fulfil our relationship with you as a supplier.This is a legal requirement and forms part of the Terms and Conditions of contract with us.
Bank detailsTo enable us to make payments, send remittances, answer queries etc. and fulfil our relationship with you as a supplier.This is a legal requirement and forms part of the Terms and Conditions of contract with us.
Unique Taxpayer Reference (UTR) Company Registration Number (CRN)To enable us to make payments, send remittances, answer queries etc and fulfil our relationship with you as a supplier.This is a legal requirement and forms part of the Terms and Conditions of contract with us.

13. If you work or volunteer for us

This includes current and former permanent, temporary and freelance staff, but also applications for advertised roles. By volunteers we include current and former house volunteers and trustees.

What We CollectWhyLegal Basis
Your name, company name, contact address, e-mail address, telephone numberTo enable us to contact staff and volunteers with work related news and information (including rotas, newsletters etc.)This is a legal requirement    
Bank detailsTo enable us to make payments, send remittances, answer queries etc.This is a legal requirement and forms part of the Terms and Conditions of contract with us.
Financial information (pension, tax details, pay details)To enable us to calculate wages and payments as part of our statutory responsibility as an employer.This is a legal requirement and forms part of the Terms and Conditions of contract with us.
Qualifications and Employment HistoryTo enable us to make informed judgements and verifications of a person’s employment suitability.This forms part of the Terms and Conditions of contract with us.
Demographic and health information (including age, disability, gender)To enable us to uphold our duties as an employer including commitment to Equality Act 2010 and to our Equality, Diversity & Inclusion and Human Rights PolicyThis forms part of the Terms and Conditions of contract with us.
Emergency Contact DetailsTo contact in case of an emergencyThis is a legal requirement  

 

14.                If we take a photo, image or video of you

Photos and videos count as data and any image taken of you where you are personally identifiable can be considered personal data. This does not include group shots where you are not the focus or images where your appearance is concealed or obscured (for example the backs of heads).

We sometimes take photos or videos of the House or at our events. Any external use of your image (photograph or video) will only be used with your permission and you will be asked to sign an image consent form, or if captured on film give verbal permission. We will then store your record of permission.

Consent can be withdrawn at any time, in which your permission will be removed and any related images or videos removed from public platforms. To withdraw permission please email enquiries@elizabethgaskellhouse.co.uk 

What We CollectWhyLegal Basis
Images or videos to document events or create promotional material for the HouseTo promote the House and its activities including via external channels such as press, newsletters and social media.Your images will only be used with explicit consent.
 To use for reporting, evaluation and advocacy purposes, including sharing with funders, Friends and other stakeholdersYour images will only be used with explicit consent.
 To create a record and archive of the House and its EventsYour images will only be shared externally with explicit consent.

15. CCTV

Elizabeth Gaskell’s House premises are protected by CCTV so you may be recorded when you visit the House.  CCTV images are being monitored and may be recorded for the purpose of public safety, crime prevention, detection and prosecution of offenders.

The system is managed in accordance with our standard operating procedures and with good practice guidance issued by issued by the Information Commissioner’s Office. CCTV images will only be accessed by authorised staff and are stored for up to 30 days, unless flagged for review.

Sharing information

We do not disclose personal data to any third parties or external organisations, other than companies carrying out work on our behalf. We retain responsibility for your data and ensure that these organisations only act on our instructions. Where your data is shared with a third party carrying out work on our behalf, a data-sharing agreement will be put in place to ensure your data cannot be used or more widely shared for any other purpose.

Examples of when we share data:

  • Email marketing services (e.g. Mailchimp)
  • Ticketing, sales and donations services (e.g. Ticket Source, Justgiving)
  • Telephone fundraising agencies working on our behalf
  • Data cleaning organisations

We may occasionally need to transfer your personal information overseas, for instance to our email marketing providers (MailChimp) or our ticketing service providers (Ticket Source). We ensure any transfers of data are secure, in accordance with best practice, and in compliance with the UK Data Protection legislation.

For information on each of these services please see:

Your data will never be sold or passed to any third party for any other purpose.

We use a third-party provider, Zoom Video Communications Inc to broadcast our online events. Zoom requires users to register in advance. When you subscribe to their service the processing of your personal data by Zoom will be covered by the terms of the agreement between you and Zoom.  For more information on how they process your personal data, please see Zoom’s privacy notice. 

Legitimate Interests

We have a number of legal bases that mean we can use (or ‘process’) your personal information. One basis ‘Legitimate Interests’, which means we can process your personal information if:

  • We have a genuine and legitimate reason
    and
  • We are not harming any of your rights and interests.


The following are some examples of when and why we would use this approach in our work:

  • Direct Marketing: We may send postal marketing and fundraising requests which further the aims and objectives of Manchester Historic Buildings Trust
  • Wealth screening and research, to help us understand our Members, donors and potential donors, including gathering information from publicly available resources to give an insight into your philanthropic interests and ability to support Manchester Historic Buildings Trust

When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests.

How we keep your information secure

We have implemented security procedures, rules and technical measures to protect the personal data that we have under our control from:

  • Unauthorised access
  • Improper use or disclosure
  • Unauthorised modification.

All our employees and data processors, who have access to and are associated with the processing of personal data, are legally obliged to respect the confidentiality of the personal data that we hold.

Further actions

  • Data Security is included in our organisational risk register which is reviewed by the board every four months.
  • A Record of all Data Processing Activity is kept and reviewed internally every six months.
  • A Data Audit will be carried out annually
  • An update on GDPR and Data Security will be presented at all AGMs to the board and Members.
  • We have appointed a Data Protection Lead, named below.
  • A Confidentiality and Data Protection Agreement is included in all Staff and Volunteer handbooks

In the event of a data breach:

We are registered with the Information Commissioner’s Office (ICO) and in the event of a data breach we will fulfill our duty of reporting a significant breach to the ICO within 72 hours.

In the event of a data breach we will follow the below process:

Potential data breach will be flagged with the staff data protection lead who will then flag with the appointed board lead for Data Protection

The Data Protection Lead and Board Lead for Data Protection will then assess the severity of breach taking into account:

i) what personal information has been breached

ii) who might now have access to personal information

iii) how might people be affected

iv) how many people will be affected

v) how seriously it might affect people

Based on the above risk assessment a decision will be made on how to contact any individuals or organisations affected by the breach, and whether the incident needs to be reported to the relevant authority. Where this is the case the full board will be notified in advance.

We will then follow ICO guidance on how to respond to a personal data breach:

https://ico.org.uk/for-organisations/advice-for-small-organisations/72-hours-how-to-respond-to-a-personal-data-breach/

All data breaches, regardless of severity, will be documented in our record of data processes including date, nature of risk and severity and any actions taken. This will be reported to the board as part of the regular board reporting cycle.

Your Data Protection Rights

Under data protection laws that took effect in May 2018, you have rights in relation to your personal data. These rights are:

The right of access: you have the right to know whether we are processing any of your personal data. If we are, you have the right to access the data and certain information, such as why we are processing the data. This is known as a Subject Access Request.

The right of rectification: you have the right to ensure that we correct inaccuracies in your personal data that we are processing

The right of erasure (the ‘right to be forgotten’): in certain situations you have the right to ensure that we erase your personal data.

The right to restriction of processing: in certain situations you have the right to ensure that we restrict our processing of your personal data.

The right of data portability: in certain situations you have the right to receive personal data that you provided to us in a structured, commonly used and machine-readable format.

The right to object: in certain situations you have the right to object to our processing of your personal data and we are normally obliged to stop processing your data when requested. This right includes the right to object to our processing of your personal data for the purposes of direct marketing

The right to complain: you have the right to make a complaint to the UK Information Commissioner’s Office (ICO) about our processing of your data, the exercise of your rights, and other data protection matters.

The right to withdraw consent: you have the right at any time to withdraw your consent for us to process your personal data.

These rights are not absolute and may not apply in all situations or in relation to all processing activities.

Requests to exercise any of these rights (including Subject Access Requests) should be sent to: enquiries@elizabethgaskellhouse.co.uk 

Sally Jastrzebski-Lloyd 
Elizabeth Gaskell’s House

84 Plymouth Grove
Manchester
M13 9LW

Changes to this Privacy Policy

We regularly review our privacy notice, and may make changes time to time. Any changes made will be posted to this page, and will apply from the time we post them. Please visit this page periodically, to ensure you are aware of any changes.

This privacy notice was last changed on Dec 2021.

How to Contact Us

To contact the appointed Data Protection lead:

sally@elizabethgaskellhouse.co.uk

Sally Jastrzebski-Lloyd 
Elizabeth Gaskell’s House

84 Plymouth Grove
Manchester
M13 9LW

If you have any comments on our Privacy Notice, or information we hold about you please contact us:

If you wish to make a complaint about data protection, you can raise this with our chair of Trustees, Alex Walker via enquiries@elizabethgaskellhoue.co.uk

Please see our complaints procedure for more information. You have the right to make a complaint directly to the UK Information Commissioner’s Office (ICO), which is the data protection supervisory authority in the UK.

The guides brought the home alive. It was inspiring to hear about this woman and extraordinary family

Visitor to the House in 2021